Keith Alan Erskine, Appellant, v. State of Florida, Appellee. (2026)

District Court of Appeal of Florida, Sixth District.

Keith Alan Erskine, Appellant, v. State of Florida, Appellee.

Case No. 6D2025-0473

Decided: September 04, 2026

Keith Alan Erskine, Cross City, pro se. James Uthmeier, Attorney General, Tallahassee, and Marilyn Frances Muir, Chief Assistant Attorney General, Tampa, for Appellee.

AFFIRMED. See Wainwright v. State, 411 So. 3d 392, 400 (Fla. 2025) (“Erlinger is not a development of fundamental significance under our existing retroactivity test.”), cert. denied sub nom. 145 S. Ct. 2789 (2025); Maye v. State, 51 Fla. L. Weekly S116, *4 (Fla. May 14, 2026) (holding that Apprendi-type claims are no longer properly raised in a Florida Rule of Criminal Procedure 3.800(a) motion), reh'g denied, No. SC2023-1184, 2026 WL 2243835 (Fla. Aug. 4, 2026).

PER CURIAM.

STARGEL, WOZNIAK and SMITH, JJ., concur.

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